CS-OIC-11 - Offers Based on Legal Arguments

Some taxpayers may make an offer based on a legal or policy argument, even though they can pay the tax liability in full either immediately or over time through an installment payment agreement.

Offers in compromise based on legal or policy arguments should be sent to the Commissioner of Revenue at the Andrew Jackson State Office Building, 500 Deaderick Street, Nashville, TN 37242. The taxpayer should submit a detailed written statement setting out their legal argument along with the offer. The taxpayer does not need to fill out the Offer in Compromise Application. Taxpayers are encouraged to consult with a tax professional before proceeding.

Please be aware that submitting an offer in compromise does not push back the legal deadline for requesting an informal conference or for filing suit to challenge an assessment. Information about your rights as a taxpayer is included with the Notice of Proposed Assessment that you received.


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